Proposed VA Service Dog Regulation — Comment Period ends August 15, 2011

Hello my friends,

I come to you today bearing good news.  That’s a change, isn’t it.  Are you ready? 
Are you a disabled Veteran with a service dog?  Are you considering getting a service dog?  Than you definitely want to read this article published by Occupational Health and Safety, entitled VA Expanding Service Dog Benefits.  The title itself is a bit of a misnomer.  The VA isn’t exactly “expanding” anything.  Not yet.  Read on.

This is a PROPOSAL to change to a current regulation already in place.  It will add SERVICE DOGS to the current VA regulation which currently covers only Guide Dogs.  Yes, some of you out there have had service dogs approved but as you know all too well it’s been a real battle.  This will (should) take the battle out of it for most of us with service dogs.  The proposed regulation will define service dogs.  It will spell out exactly what is covered by VA Prosthetics.  It is also supposed to spell out the steps for applying — something which varies from VA Hospital to VA Hospital.  Wouldn’t it be nice to have a standard?
READ THE FULL TEXT HERE:  I suggest each of you take the time to read this carefully.  It describes the proposed changes to the current regulation.  Take notes if you have to of things you don’t agree with.  It will help you to better prepare your comments on this proposal.

HOW CAN YOU HELP? It’s easy and it will only take a few minutes of your time.  Go to  There you will see a search key.  In the box above it, enter the following, “VA-2011-VHA-0017-0001: AN51-Proposed Rule -Service Dogs” (minus the quotation marks).  You have until August 15, 2011 to make comments.  State facts.  Leave emotions out of it.  We all know the VA doesn’t care about our emotions or how broke we are.  Remember to compare it to a prosthetic device.  State why you can’t use a standard prosthetic device and why a SD is better for you.  The VA will replace and pay to repair our prosthetic devices.  Why shouldn’t they pay to maintain our dogs?  These are working dogs, not pets.

SPREAD THE WORD.  Share this blog with every service dog organization you know.  Ask them to comment on this proposed regulation.  We need to get the word out.  Share this with every Veteran you know who has a service dog.  The more comments we have the better off we are.  We want the VA, particularly Neal Eckrich, to know that we are paying attention.  In your comments, tell him what type of service dog you have, not the breed, but what the dog does to assist, as in mobility, seizures, balance, etc.

WHAT THIS IS NOT.  This is not for PTSD or mental health dogs.  Let’s be clear about that.  The VA is currently conducting a three year study on the effects of PTSD dogs and their “value” to those of us with PTSD.  This is strictly about service dogs that assist us with mobility issues, seizure issues, etc.  Read the proposed explanation for further details.  
Good luck everyone.  Remember, spread this blog far and wide.  Encourage everyone you know to comment on this proposed regulation.  Let the folks at VA HQ in DC know we are paying attention and we’re not going to let this one get by us without our comments.  This is too critical for all of us to do nothing.

Until the next time I leave you with these photos of Rocco and me out on the town.  I couldn’t have done this without Rocco.  Thanks to Service Dogs of Florida for helping me train and certify him!


How much is that Doggie in the Window, Part Two.

Hello, Invisible Reader.  It’s been a while since we talked about service dogs so I figured it was time for an update. Since my first post about service dogs on April 18, 2010, I’ve learned much about service dogs and I’d like to share that with you.  

I guess the beginning is always the best place to start.  Let’s rewind back to March, 2010, when I lost my beloved Doberman, Puzzle, to a form of cancer called lymphoma.  It came on fast and there was no chance of saving her.  I wrote that blog in April while the pain was still fresh and raw.  I miss Puzzle.  She was a such a sweet dog and there is no replacing her. 

Puzzle pretending to be an old Granny

I had started looking into Service Dog Schools and found good ones and less than reputable ones.  At the suggestion of Ken Lyons of Service Dogs of Florida, Inc. (SDFL), I didn’t give up hope and kept applying.  Ken already had me penciled in for Charity but he’d warned me that it could be a year or more before Charity would be ready for me, IF she even made it through his rigorous training program. Ken puts each and every one of his dogs through a tough training and credentialing program.  If they don’t make it past Assistance Dogs International training standards, he’ll wash them out of his program.  Some might make it as therapy dogs, others will be placed into pet homes.  Only the very best dogs will earn an SDFL patch and the title of “service dog”.

I knew two things for certain.  One, I couldn’t wait a year or longer for a service dog.  Two, I couldn’t stand to be without a Doberman.  After doing further research I realized I’d made a terrible mistake.  Working dogs such as German Shepherds and Dobermans CAN make good service dogs as long as they have the right temperament.  For that reason it’s imperative that you have a breed specific expert assist you in finding the right dog.  Just any old dog won’t do.

I’ve already told you about my background in dogs.  If you’ve forgotten or you’re reading my blog for the first time, click on the link in the first paragraph to Part One for my “history”.  Very quickly, I’ve been around the professional sport of AKC obedience dog training and dog showing almost my entire life and I have “connections” in the dog world.  When I decided to get a Doberman, I reached out to an old family friend who has known me since I was three years old … in other words, for close to 48 years.  Not only does Esther know me well, she is one of the foremost authorities of Dobermans in the United States.

Esther reached out to her friend, Jinx, who works with Spay-Lee Rescue, Inc., here in Florida.  Unbeknownst to me, Jinx had known my mother from back in the 60’s, as long as Esther did. Spay-Lee is an all-breed rescue but they specialize in Dobermans.  Esther and Jinx set out to find me the perfect Doberman.  They know I suffer from PTSD and major depressive disorder.  They know I have mobility issues.  They know I want to train my own service dog and with the guidance from the right trainer, I’m fully capable of reaching this goal.  All I needed was the right dog.  Between Jinx and Esther they have over 100+ years of “Doberman experience”.

The call came from Esther that they’d narrowed my choice down to two dobermans.  All we had to do was drive to Sarasota to meet them.  We packed up Manor, our little dog, picked up Esther, and the four of us were on our way to meet the dogs.

It was love at first sight.  Had we lived in a larger house, Terri and I would’ve come home with two Dobermans that day.  Alas, we had to choose just one.  There was a pretty little bitch who was the sweetest thing.  Sadly, in her previous life she’d been hit by a car.  Her pelvis had not healed correctly and though she didn’t seem to care, I worried that the long term effects would be a problem in the future.

Really sweet girl who was also looking for a home.

The other dog they brought for us was a handsome, red male.  His tail was already docked but his ears were natural.  He was young; 8 months old.  They estimated he was born in October 2009.  He’d recently been neutered so he was full of puppy energy and testosterone.  What most people fail to realize is that neutering a dog doesn’t instantly get rid of the testosterone.  It takes about six months to get it out of their system.

The male we were looking at.  He was checking out Manor.  See her in the lower left corner looking on?

We had Manor, our resident Old Girl with us.  It was important that she be included in the decision.  After all, she’s been with me for many years.  She’s about 12 years old and this is her house, too.  If she didn’t like either of the dogs than it wasn’t going to be a dog that went home with us.  We were meeting on neutral territory which is necessary when making a decision like this.

Manor, the “Old Girl” of our house

The decision wasn’t difficult to make once I realized I had to make a rational one.  My heart told me to take both dogs home.  My reasonable self, and my wife (the smart  and more rational one) told me to take the male.  We did the required paperwork, loaded the dogs into an air-conditioned van and then ate lunch to celebrate.  The fun and hard work was just beginning.  I had a new Doberman and I was one happy camper.

I have to point out that my wife, Terri, wanted an Australian Shepherd.  She’s wanted one for a very long time.  Bless her heart she gave up her dream dog so that I could have my Doberman.  The Dobe we’d just adopted came with the name “Rocco”.  I hated the name from the instant I heard it and wanted to change it.  Terri loved the name.  What’s a girl to do?  I took away her Aussie.  I had to let her have the name.  So now we have Rocco and she tells everyone he’s the Aussie she was supposed to have.  đŸ˜‰  Some day Terri will have her Aussie.  Just as soon as I can afford to buy my wife a bigger house, my first purchase (after the house of course) will be an Aussie puppy.  My wife has certainly earned it after giving up so much for me.

After lunch we loaded up Rocco into our car and started the ride to his new home.  We weren’t sure what we were in for.  Esther and Manor were in the back seat.  Poor Esther.  Manor is a chronic, almost obsessive licker (think OCD) and Esther was her captive audience for the ride back to Palm Harbor.  Rocco went into the back of the car and settled down quietly, watching the road pass him by, wondering, no doubt, where he was going now.

Rocco on his way to his new home.

Rocco had only been in rescue for a couple of weeks.  Not much was known about him.  He’d been turned in to Miami-Dade Animal Control and they wanted to put him down because he had “cancer” on his elbow.  It wasn’t cancer.  It was a hygroma, something common in Dobermans but the inexperienced folks at MDAC didn’t recognize that.  Fortunately for me, they called Spay-Lee and Spay-Lee saved the day.  More to the point, they saved Rocco’s life.

About a week after we brought Rocco home, we had to return him to Spay-Lee for surgery on the  hygroma.  It was rough on Rocco and rough on us.  He’d spent a few days at the pound, two weeks in rescue, a week with us and then he had to go back to Spay-Lee for another week.  Poor guy … would his life ever settle down?  I can’t imagine what he was thinking.

One week later we picked our boy up.  The surgery was a success and we could have our own Veterinarian do the post-op follow-ups.  Little did we know what was ahead for Rocco.  Our poor dog had already seen so much in his young life and still — he’s a real trooper.

All bandaged up after surgery.

Rocco with his “cone” on.  Poor Baby.

Rocco got sick after surgery.  His platelet count dropped and he started to hemorrhage.  He had red spots all over his belly, inside his ears, inside his mouth … it was terrifying to me.  I thought… My G-d, you just gave me this incredible dog.  Don’t let me lose another one.  I won’t tell you how much money we spent getting him well again but it was money well spent.  Spay-Lee offered to take him back for a second opinion on the diagnosis (which is not relevant to this story) but I turned them down because that meant being away from him for another week.  Antibiotics, steroids, pain meds, lab work.  I believe Veterinarians are underpaid and you won’t get me to change my mind about that one.  I’ll never disagree with the cost of a Vet bill no matter how outrageous you think it is.  I worked for many years in the animal health care field.  I know how expensive it is to own and operate your own Veterinary Hospital.  If you think the average Veterinarian is making money hand over fist you are sadly mistaken. (stepping down off my soap box now)

After a couple of frightening weeks, Rocco healed up nicely.  He’s now an active, happy dog and he loves to play and train.  Right now he wants a potty break and he’s telling me about it.  Back shortly, Invisible Reader!

Once Rocco got the “go ahead” from our Veterinarian, his training (and mine) began in earnest.  We hooked up with an amazing young woman by the name of Emily who lives in Naples.  Emily is 13 years old and she’s had service dogs since she was five years old.  Mind you, Invisible Reader, this all falls under the Service Dogs of Florida, Inc., umbrella.  They will be the ones to ultimately test and certify Rocco when he is ready for it. It will take us approximately two years of training before Rocco is fully trained but even then, the training will always continue.

Emily and Rocco at the Park

But back to Emily.  I hooked up with Emily through Facebook.  Ahhh, the wonders of the internet.  Emily offered to help me train Rocco.  Little did she know I had already hooked up with Ken and SDFL.  It’s a small world, isn’t it?  The more I learned about Emily the more impressed I was with this amazing young teenager.  Emily once had a long term goal of being the Navy’s first Woman SEAL.  She was taught how to swim by a former SEAL and she was so inspired by him that she wanted to be a SEAL like he was.  Unfortunately, Emily has issues that will keep her from joining any of the armed forces.  Do you think that stopped Emily from wanting to serve her Country?  No way.  Not this young lady.

Emily has a new focus.  Some day Emily wants to open up her own service dog school.  Her goal is to train service dogs and give them to Veterans.  She was thrilled to find out that I am a Veteran and offered to help me train my dog.  Already, I have learned so much from this young woman.  She is a wealth of information and knowledge.  I have to stop and take a deep breath and remember that I’m talking to a 13 year old when we’re chatting.  She’s wise beyond her years.  

I am Emily’s “First Veteran”.  Her dog, “Bella” is an “owner-trained” service dog, certified by SDFL.  I’m going to train Rocco under the SDFL umbrella, with Emily’s help.  I’m honored to have her help me.

Emily and her service dog, Bella

Training a service dog is a long process.  It doesn’t matter if you’re an owner trainer or if your dog is school trained.  It’ll be at least two years before Rocco is ready to be tested by SDFL to become a “Certified” service dog.  Until then, he’ll be an “SDIT”, “Service Dog in Training”.  He has a great many tasks to learn.  He has basic obedience to learn.  He has to pass the AKC Canine Good Citizenship Test.  He will need thousands of hours of public access time.  That’s just the beginning.

Everything that Rocco and I learn, and this is a learning process for both of us, believe me, has to be documented.  Each time Rocco and I go out in public has to be carefully recorded.  Where we went, how long we were out in public together, date, time, details, details, details.

What amazes me most is how incredibly fast Rocco is learning.  I could brag and tell you I’m a great trainer.  But that wouldn’t be the truth.  The truth is, he’s just a smart dog.  He’s totally devoted to me.  He’s a quick learner and he wants to please me.  As I write this, he’s laying at my side, ever watchful.  He knows when I’m upset, when I’m tired, when I need help standing up, when I need help balancing.  He’s learning his obedience skills quickly.  

He’s not perfect.  I have to remember he’s still a puppy and he LOVES to play.  When he’s off leash and we’re out in the yard he’s easily distracted by birds flying overhead.  The funny thing is, we have five pet birds of our own and he doesn’t give a damn about them.  He totally ignores them.  

He loves to chase “his” ball.  We work on his obedience training in the yard.  I can’t leave the house during the week.  If you’re a regular reader you know I don’t drive anymore so leaving the house when my wife is at work is virtually impossible.  It’s okay though.  We work on his obedience training in the yard where there are natural distractions.  Those are healthy distractions for him.  Since he’s young, we train for a short time, then play for a short time.  We do this several times a day.  By doing several short training sessions daily, Rocco doesn’t get bored.  In between training sessions, he gets to play “ball” as a reward.

Playing “ball” is hysterical.  I have lousy shoulders as you already know, Invisible Reader.  I can’t really throw the ball well anymore.  Rocco doesn’t care.  He’ll chase it even if it only goes five feet.  He brings it back to me and then the fun begins again until my shoulder is hanging at my side and I just can’t do it anymore.

Let’s switch our focus, Invisible Reader.  You’re used to that with me if you’re a regular reader.  If this is your first time reading my blog you’d better get used it.  My mind jumps all over the place which is one of the reasons the word “Ramblings” is included in the title of this blog.

What can the Veterans Administration do for you if you have a service dog?  They can do plenty if you know where to look and in some cases you’re ready to fight for what you deserve and have earned.  Let’s start at the beginning.  That’s always the best place to start, right?  Everything you need to know is listed below.  Almost.

AMVETS works with VA Prosthetic and Sensory Aides Services to Clarify Title 38 Entitlement
WASHINGTON, April 26, 2010—This week VA clarified a scarcely known benefit in Title 38, offering benefits to veterans using certain types of assistance dogs. AMVETS, which recently called attention to Title 38 Section 1714, successfully received guidelines from VA on how to properly file for the benefit. AMVETS encourages any veteran with an assistance dog, previously denied or awaiting approval of this benefit, to re-apply immediately.

Veterans interested in applying for benefits for their assistance dogs must directly request their VA caseworker to immediately file VA Form 10-2641 (internal use only) and proper accompanying paperwork. A sample copy of the form has been furnished by VA, which you can downloaded below, and printed out by veteran to bring to their next visit to ensure the proper forms are filed and to act as a guide for caseworkers. AMVETS has also provided a link to Title 38, Section 1714, which outlines eligibility criteria for veterans to receive service dog benefits and covered expenses.

VA Prosthetic and Sensory Aides Services, or PSAS, which has recently gone above and beyond in the continued development of the program and the proper implementation of this benefit, has assured AMVETS that claims will be adjudicated within 10 days of receipt of the veteran’s form 10-2641 filed by the veteran’s individual VA caseworker.

The form includes a section outlining the specific tasks performed by the assistance dog. To date, VA does not have the authority to approve applications filed exclusively for PTSD, but is currently conducting a pilot study on the healthcare benefits to veterans for possible inclusion of psychiatric service dogs to Title 38 benefits.

Over the last two weeks, AMVETS members Luis Montalvan, an OEF/OIF veteran, and Kevin Stone, a Paralympic bronze medalist, both received approval of benefits for their assistance dogs Tuesday and Mambo. Montalvan and Stone are the two veterans whom accompanied AMVETS and partner non-profit assistance dog agency Paws With A Cause on recent meetings with legislators and policy-makers in Washington.

All applicants are encouraged to review their cases one on one with their individual caseworker and gather any necessary paperwork prior to the initial filing or re-filing of VA Form 10-2641 to ensure the expected timelines are met. AMVETS commends PSAS for their ongoing efforts in ensuring all veterans with assistance dogs meeting the criteria outlined in Title 38 receive their due entitlements.

VA Form 10-2641 Sample

VA Prosthetics and Sensory Aides Services FAQ on Service Dogs

Title 38, Section 1714 as of April 2010

This comes from the VA Website.  Every Veteran who is interested in obtaining services for their service or guide dog from the VA should read this:

Guide and Service Dogs Frequently Asked Questions (FAQs)
To support an active and independent lifestyle VA provides benefits for guide and service dogs.  The job of a guide dog is to assist the blind.  A service dog assists someone with a severe to profound hearing impairment or someone with a physical impairment that substantially limits mobility.

  1. What is the difference between a guide dog and a service dog?
  2. How do I determine if I am eligible for a service dog through VA?
  3. Does VA actually provide the guide or service dog?
  4. If it is determined that I am eligible for a service dog, what benefits does VA provide for my guide or service dog?
  5. Does a service dog serve the same function(s) as Animal Assisted Therapy or Animal Assisted Activity dogs?

A guide dog is trained to assist the blind.  A service dog is trained to help those with severe to profound hearing loss by alerting the individual to a variety of sounds or someone with a physical impairment that substantially limits mobility  by assisting in the performance of a wide variety of tasks depending on need and training (e.g. opening doors, retrieving, etc.).

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To receive any type of medical service through VA, you must register at the Health Administration/enrollment section of a VA Medical Center or online: Once registered, a referral to a specialist may be requested through the assigned VA primary care provider. The Veteran’s VA medical team will perform a complete clinical evaluation to determine how best to assist the Veteran.  Each guide and service dog request is reviewed and evaluated on a case-by-case basis.

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 No. Veterans approved for guide or service dogs are referred to accredited agencies.  Many of these organizations do not charge for the dog or the dog’s training.
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VA will pay for veterinary care and the equipment (e.g. harness and/or backpack) required for optimal use of the dog. Veterinary care includes prescribed medications, office visits for medical procedures, and dental procedures where the dog is sedated (one sedated dental procedure will be covered annually). Vaccinations should be current when the dog is provided to the Veteran through an accredited agency. Subsequent vaccinations will be covered by VA. Prescribed food will be reviewed on a case-by-case basis.
Veterinary care does not include over-the-counter medications, food, treats and nonsedated dental care. Flea and tick medications are considered over-the-counter and are the responsibility of the Veteran along with over-the-counter dental care products (bones, dental treats, etc.). Grooming, boarding and other routine expenses are not covered.

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No. Animal Assisted Therapy and Animal Assisted Activity dogs are used either to assist therapists to accomplish therapeutic goals or for general engagement of the patients.  Neither type of dogs is for personal use by the Veteran. They are used only in a medical setting.

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I’m attacking this through my ILP plan.  The problem is that this is such a new program that you have to be very aggressive or you’re not going to get any help from the VA.  I just received an email from my Voc Rehab counselor that she’s going to add my service dog into my ILP plan.  That means the VA will be paying for anything that I need for him within the limits of the program.

If you aren’t in Voc Rehab or the ILP, all you need to do is have either your primary care physician or psychologist/psychiatrist, fill out the required VA Form 10-2641 (it’s an in house form) stating your service dog is a medical necessity.  The form then goes to the Prosthetics section.  According to the news article on the AMVETS website, Prosthetics has ten days to respond.

This is a good start for you, Invisible Reader.  I’ve given you plenty to read and digest.  It’s not easy to get a service dog.  Each year there are 25,000 applications submitted nationally for service dogs.  Unfortunately, there are only 2500 service dogs ready to be placed in homes each year.  You have to be careful when you apply for a service dog.  Do your homework.  Make sure the schools you apply to are ADI accredited schools.  America’s VetDogs, Canine Companions for Independence, Inc., Service Dogs of Florida, Inc., are all good schools.  There are a lot more out there, Invisible Reader.  I encourage you to apply to as many schools as possible.  You may be accepted by some and rejected by others.  Don’t put all your eggs in one basket.  If you’re looking for info on Psychiatric Service Dogs, this is the place to get information.  Another good source is this blog post by Angela Peacock.

The internet has tons of information, Invisible Reader.  I’ve collected a lot of information by researching it myself and networking with other service dog owners.  I’ll be keeping you up to date on our progress and in time, I’ll organize my bookmarks and I’ll post them here for you.  If you’d like to see them there are pictures of Rocco and I on my Facebook page from some of our training sessions. Just send me a friend request  and add a message to your request that you’re a blog reader. I try to keep track of where my “friends” are coming from.

One last request, Invisible Reader, before I sign off.  Most of these places give these dogs away for free.  However, on average it costs $38,000 to buy, feed, train, house and purchase equipment for a service dog while it’s in training.  If you can, please donate to the service dog school of your choice.  These are nonprofit schools and your donation is tax deductible.The school will appreciate it and so will the recipient of the dog when the dog is ready to be placed.  Most schools place these dogs for free.  My school, Service Dogs of Florida, doesn’t charge the handlers for the dog even though it costs them a small fortune to train these dogs and get them ready for placement.  Look deep into your heart, Invisible Reader.  I know times are tough right now.  But if you can help ….. please do.  You won’t be sorry.

Until the next time, Invisible Reader ….